3.2) persons who use or wish to use the service to attend events as attendees;

3.3) persons who are employed by Brella Oy or seek employment from Brella Oy; and

3.4) other persons who contact Brella Oy via email or through the service.

In this Privacy Policy data subjects may also be referred to as “you”.

4) THE CATEGORIES OF PERSONAL DATA

The data files concerning the data subjects of Sections 3.1) – 3.4) may contain the following categories of personal data:

contact information, such as full name, address, phone numbers and e-mail addresses;

data about your device, such as information about the device you use, the type of your device, your IP-address and various diagnostic data;

if you use your device to connect to a third-party service, such as Facebook, Twitter or LinkedIn, we may, with your consent, collect data you provide to this particular third-party, such as your contacts, calendar entries, photos, log in information and such like data you give to this particular third-party service; and

possible other information gathered with the data subject’s consent.

The data files concerning the data subjects of Section 3.1) may also contain the following categories of personal data:

user information, such as username, password and other unique identification browsing, search information and other information concerning your use of our services;

location information, such as GPS-coordinates, data of your wireless connection (SSID) and strength of your Wi-Fi signal; and

The data files concerning the data subjects of Section 3.3) may also contain the following categories of personal data:

personal identification numbers;

nationality, age, gender, title or profession and mother tongue;

employment history; and

bank account data.

The data files concerning the data subjects of Section 3.4) may also contain the following categories of personal data:

personal identification numbers; and

any other information provided by the person contacting us.

5) PURPOSE OF THE PROCESSING OF PERSONAL DATA

Personal data of the data subjects of Sections 3.1) – 3.4) can be handled for the following purposes:

customer service;

for improving our user experience;

to enable us to comply with our legal and regulatory obligations; and

analysis and statistics.

Personal data of the data subjects of Section 3.1) can also be handled for the following purposes:

management and development of the customer relationship; and

marketing, market surveys and studies.

Personal data of the data subjects of Section 3.2) can also be handled for the following purposes:

management and development of the customer relationship; and

marketing, market surveys and studies.

Personal data of the data subjects of Section 3.3) can also be handled for the following purposes:

management and development of the employee and jobseeker relationships; and

management of employment contracts and other related matters.

Personal data of the data subjects of Section 3.4) can also be handled for the following purposes:

management of contacts; and

marketing, market surveys and studies.

Personal data can also be processed by other Brella Oy’s Finnish affiliate companies, if any, in accordance with the Finnish Personal Data Act, the GDPR and the Finnish Data Protection Act.

6) LEGAL BASIS FOR PROCESSING

The controller has the right to process the personal data of the data subjects based on the:

consent received from the data subjects;

performance of a contract in which the data subject acts as the contact person of the organizer; or

legal obligation to which the controller is subject.

To the extent prohibited by applicable law, Brella we do not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us. We will takes steps to delete such information.

7) REGULAR SOURCES OF INFORMATION

Information regarding the data subjects are regularly gathered:

from data subjects themselves via phone, internet, e-mail or in other similar fashion;

with cookies and other similar tech;

by Brella Oy’s other Finnish affiliate companies; and

from the Population Register Center/Population Information System, Posti’s address database, phone companies’ databases and other similar private and public registries.

8) PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The controller shall not store the personal data longer than is necessary, taking into consideration the purpose for the processing of personal data.

If a jobseeker is not chosen for the position she applied for, we shall not store any data of her without her consent. If we do not receive her consent, we destroy her data immediately. If she gives us her consent, we may store her data for six (6) months, after which we will destroy all such data.

The controller inspects monthly the necessity of the personal data stored.

9) CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The recipients of personal data may consist of the following categories:

Brella Oy’s Finnish affiliate companies;

third parties who offer cloud services;

third parties who offer accounting and auditing services;

third parties who help Brella Oy to fulfill its legal obligations; and

organizers and attendees.

All other information than information concerning data subjects of Section 3.3) may be disclosed with the data subject’s consent for marketing purposes in accordance with the Finnish Personal Data Act and the GDPR.

10) REGULAR DISCLOSURE OF DATA AND INFORMATION TRANSFER OUTSIDE OF EU OR THE EUROPEAN ECONOMIC AREA

Information may be transferred and stored to a server outside of EU or the European Economic Area to be processed by the Controller or Controller’s affiliate on Controller’s behalf in accordance with the Finnish Personal Data Act, the GDPR and the Finnish Data Protection Act.

11) DATA SUBJECTS’ RIGHTS

The data subject has a right to use all of the below mentioned rights.

The contacts concerning the rights shall be submitted to the person in charge of the data file stated in Section 2. The rights of the data subject can be put into action only when the data subject has been satisfactorily identified.

Right to inspect

Having presented the adequate and necessary information, the data subject has the right to know what, if any, data the controller has stored of her/him into this register. While providing the requested information to the data subject, the controller must also inform the data subject of the register’s regular sources of information, to what are the personal data used for and where is it regularly disclosed to.

Right to rectify and erasure

The data subject has a right to request the controller to rectify the inaccurate and incomplete personal data concerning the data subject.

The data subject can request the controller to erase the personal data concerning the data subject, if:

the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

the data subject withdraws consent on which the processing is based on;

the personal data have been unlawfully processed; or

the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

If the controller does not accept the data subject’s request to rectify or erase the personal data, it must give a decision of the matter to the data subject in a written form. The decision must include the reasons for which the request was not granted. The data subject may refer the matter to the relevant authorities (Data Protection Ombudsman).

The controller must inform the party to whom the controller has disclosed the personal data to or has received the personal data from of the rectification or erasure of personal data. However, there is no such obligation where the fulfilment of the obligation would be practically impossible or otherwise unreasonable.

Right to restriction of processing

The data subject can request the controller to restrict the processing of the personal data concerning the data subject where one of the following applies:

the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; or

the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

If the controller has based the restriction of the processing of personal data on the abovementioned criteria, the controller shall give a notification for the data subject before removing the restriction.

Right to object

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning her/him for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Right to data portability

The data subject shall have the right to receive the personal data concerning her/him, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.

Right to withdraw consent

Where the legal basis for the processing of personal data is the consent of the data subject, the data subject shall have the right to withdraw her/his consent.

12) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Data subject shall have the right to lodge a complaint with a supervisory authority, if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. The complaint can be lodged in the Member State of her/his habitual residence, place of work or place of the alleged infringement.

13) MERGERS AND ACQUISITIONS

In connection with mergers, acquisitions or divestiture of all parts of Brella Oy’s business, the acquiring entity, as well as its business partners will obtain access to data managed by Brella Oy, and this may include personal data. In the aforementioned case, such external parties will enter into a non-disclosure agreement with Brella Oy, which covers the potential disclosure of personal data.

14) DATA PROTECTION PRINCIPLES

Brella Oy uses all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect personal information from unauthorized or inappropriate access, but Brella Oy note that the Internet is not always a secure medium. Brella Oy restricts access to information about data subjects only to the personnel of Brella Oy that need to know the information e.g. for responding to inquiries or requests made by the data subjects.

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